K Number
K171111
Device Name
Sculpsure
Manufacturer
Date Cleared
2017-06-13

(60 days)

Product Code
Regulation Number
878.5400
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Cynosure SculpSure™ is intended for non-invasive lipolysis of the abdomen, flanks, back, and thighs in individuals with a Body Mass Index (BMI) of 30 or less. The device is intended to affect the appearance of visible fat bulges in the abdomen, flanks, back, and thighs.
Device Description
The Cynosure SculpSure is a diode laser system. The main components of SculpSure are a console and four applicators that deliver the laser energy to the patient. Electrically efficient semiconductors generate optical radiation (1060 nm) which is used to deliver laser energy to subcutaneous tissue layers.
More Information

Cynosure SculpSure K160470, Zeltiq Coolsculpting K162050

No
The summary describes a laser system for fat reduction and does not mention any AI or ML components or functionalities.

Yes.
The device is intended for non-invasive lipolysis to affect the appearance of visible fat bulges, which is a therapeutic intervention.

No

The device is intended for non-invasive lipolysis (fat reduction) to affect the appearance of visible fat bulges, which is a therapeutic rather than a diagnostic purpose.

No

The device description explicitly states it is a "diode laser system" with "a console and four applicators that deliver the laser energy to the patient," indicating it is a hardware-based device.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body, such as blood, urine, or tissue, to provide information for diagnosis, monitoring, or screening.
  • SculpSure's Function: The Cynosure SculpSure is a laser system that delivers energy to the body for non-invasive lipolysis (fat reduction). It directly interacts with the patient's body and does not analyze samples taken from the body.

The description clearly states its intended use is for "non-invasive lipolysis of the abdomen, flanks, back, and thighs" and that it "delivers the laser energy to the patient." This is a therapeutic or aesthetic device, not a diagnostic one.

N/A

Intended Use / Indications for Use

The Cynosure SculpSure™ is intended for non-invasive lipolysis of the abdomen, flanks, back, and thighs in individuals with a Body Mass Index (BMI) of 30 or less. The device is intended to affect the appearance of visible fat bulges in the abdomen, flanks, back, and thighs.

Product codes

PKT

Device Description

The Cynosure SculpSure is a diode laser system. The main components of SculpSure are a console and four applicators that deliver the laser energy to the patient. Electrically efficient semiconductors generate optical radiation (1060 nm) which is used to deliver laser energy to subcutaneous tissue layers.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

abdomen, flanks, back, thighs

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Prospective, controlled studies were conducted at 3 study centers to evaluate the safety and efficacy of Cynosure SculpSure laser for the non-invasive fat reduction of the inner thigh, outer thigh and back. The study was conducted in the same manner as the previous abdomen and flanks studies. The treatment techniques used and subsequent follow up schedule for the study were kept consistent between the studies. A total of 168 subjects, making up 214 treatment areas, were enrolled in the study. This is broken down into 55 subjects/55 treatment areas for back, 52 subjects/52 treatment areas for outer thigh, and 61 subjects/107 treatment areas for inner thighs.
Each subject received 1 treatment with the SculpSure. Treatment effectiveness was assessed through blind evaluation of pre and post treatment (12-week) photographs; percentage change in the adipose tissue thickness from baseline to the12-week follow up measured through ultrasound imaging; and patient satisfaction measured at the 12-week post treatment follow up visit through a 6-point Likert scale. All subjects that were treated in the study were included in the safety analysis and adverse events were assessed at all visits. On an average, blind evaluators were able to identify 86% of the post treatment photographs (back 91%, outer thigh 87% and inner thigh 83%); ultrasound imaging at 12-week post follow up visit showed 8.6% normalized fat reduction (back 10.6%, outer thigh 7.2%, and inner thigh 8.0%). All treatments had a p-value of

§ 878.5400 Low level laser system for aesthetic use

(a)
Identification. A Low Level Laser System for Aesthetic Use is a device using low level laser energy for the disruption of adipocyte cells within the fat layer for the release of fat and lipids from these cells for noninvasive aesthetic use.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Guidance for Industry and Food and Drug Administration Staff; Class II Special Controls Guidance Document: Low Level Laser System for Aesthetic Use.” See § 878.1(e) for the availability of this guidance document.

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Image /page/0/Picture/2 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus symbol, which is often associated with healthcare. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the symbol.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

June 13, 2017

Cynosure, Inc Ms. Amy Tannenbaum Regulatory Affairs Specialist 5 Carlisle Road Westford, Massachusetts 01886

Re: K171111

Trade/Device Name: Sculpsure Regulation Number: 21 CFR 878.5400 Regulation Name: Low level laser system for aesthetic use Regulatory Class: Class II Product Code: PKT Dated: April 13, 2017 Received: April 14, 2017

Dear Ms. Tannenbaum:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Actinclude requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device

1

related adverse events) (21 CFR 803): good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely,

Jennifer R. Stevenson -S3

For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K171111

Device Name SculpSure™

Indications for Use (Describe)

The Cynosure SculpSure™ is intended for non-invasive lipolysis of the abdomen, flanks, back, and thighs in individuals with a Body Mass Index (BMI) of 30 or less. The device is intended to affect the appearance of visible fat bulges in the abdomen, flanks, back, and thighs.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)

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Section 5

510(k) Summary

510(k) Summary for SculpSure Laser System

A summary of 510(k) safety and effectiveness information in accordance with the requirements of 21 CFR 807.92.

807.92(a)(1) Submitter Information
ApplicantCynosure, Inc.
Address5 Carlisle Road
Westford, MA 01886
Phone Number(781)-993-2454
Fax Number(978) 256-6556
Establishment Registration
Number1222993
Contact PersonAmy Tannenbaum
Preparation DateApril 13, 2017
807.92(a)(2) Name of Device
Trade or Proprietary NameSculpSure
Common or Usual NameLaser
Classification NameLaser for disruption of adipocyte cells for aesthetic use
Classification PanelGeneral & Plastic Surgery
Regulation21 CFR 878.5400
Regulatory ClassII
Product Code(s)PKT
807.92 (a)(3) Legally marketed device(s) to which equivalence is claimed
Predicate DevicesCynosure SculpSure K160470
Zeltiq Coolsculpting K162050
The predicate devices have not been subject to a design-related
recall.
807.92(a)(4) Device Description
The Cynosure SculpSure is a diode laser system. The main
components of SculpSure are a console and four applicators that
deliver the laser energy to the patient. Electrically efficient
semiconductors generate optical radiation (1060 nm) which is
used to deliver laser energy to subcutaneous tissue layers.
807.92(a)(5) Intended Use of the Device
The SculpSure laser system is intended for non-invasive lipolysis
of the abdomen, flanks, back, and thighs, in individuals with a

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Section 5

510(k) Summary

807.92(a)(6) Summary of the Technological Characteristics of the Device Compared to the Predicate
Proposed SculpSure Laser SystemCynosure SculpSure Laser SystemZeltiq Coolsculpting Device
510(k) NumberPendingK160470K162050
ManufacturerCynosure, Inc.Cynosure, Inc.Zeltiq Aesthetics, Inc.
Lipolysis MethodHeat-assistedHeat-assistedCold-assisted
Device TypeDiode LaserDiode LaserN/A
Wavelength1060 ±20 nm
(infrared)1060 ±20 nm
(infrared)N/A
Spot Size4 x 6 cm² on each of
the Applicator heads4 x 6 cm² on each of
the Applicator heads4.5 x 7 cm² (2x)
approximate
Pulse Width (laser ON time)CWCWN/A
Power DensityUp to 1.4 W/cm²Up to 1.4 W/cm²N/A
Attachment to patientBeltBeltBelt
Voltage200-240V~, Single Phase200-240V~, Single PhaseN/A
Current20A20AN/A

807.92(b)(1) Non-clinical tests submitted

There have been minor changes to the software from the previously cleared SculpSure in K160470. These changes have been addressed and additional information is available in Section 16. There have been no changes to the biocompatibility or electrical safety testing from the previously cleared SculpSure device. Additional information is available in Section 15 and Section 17, respectively.

807.92(b)(2) Clinical tests submitted

Prospective, controlled studies were conducted at 3 study centers to evaluate the safety and efficacy of Cynosure SculpSure laser for the non-invasive fat reduction of the inner thigh, outer thigh and back. The study was conducted in the same manner as the previous abdomen and flanks studies. The treatment techniques used and subsequent follow up schedule for the study were kept consistent between the studies. A total of 168 subjects, making up 214 treatment areas, were enrolled in the study. This is broken down into 55 subjects/55 treatment areas for back, 52 subjects/52 treatment areas for outer thigh, and 61 subjects/107 treatment areas for inner thighs

5

Each subject received 1 treatment with the SculpSure. Treatment effectiveness was assessed through blind evaluation of pre and post treatment (12-week) photographs; percentage change in the adipose tissue thickness from baseline to the12-week follow up measured through ultrasound imaging; and patient satisfaction measured at the 12-week post treatment follow up visit through a 6-point Likert scale. All subjects that were treated in the study were included in the safety analysis and adverse events were assessed at all visits. On an average, blind evaluators were able to identify 86% of the post treatment photographs (back 91%, outer thigh 87% and inner thigh 83%); ultrasound imaging at 12-week post follow up visit showed 8.6% normalized fat reduction (back 10.6%, outer thigh 7.2%, and inner thigh 8.0%). All treatments had a p-value of